For distributed mutual exclusion problem in mobile environment the authors presented two algorithms. Both the algorithms are token based. The first algorithm is providing tokens to the nodes which are in critical section and the second one is hierarchical clustering based. A Mobile Ad-hoc NETworks (MANETs) is hierarchically (two level) clustered to get logical tree network through which the token is passed from one node to another. However, they simulate the second algorithm only. The evaluation of the proposed algorithms show that its message requirement is optimal, and thus the second algorithm is an energy efficient algorithm.